Sec. 92C of Income Tax Act, 1961—Transfer Pricing—A company primarily deriving its income from manufacturing/trading and indenting services cannot be a good comparable to a company rendering market support services. Transfer Pricing Officer has excluded the comparable of assessee without giving an opportunity to the assessee to dispute its exclusion, therefore the issue was remitted back to the file of Transfer Pricing Officer/ Assessing Officer for considering the inclusion/exclusion of this comparable after giving sufficient opportunity to the assessee to put forth their objections. Company engaged in the distribution and sale support of highly technical machines and pharmaceuticals, besides trading and day indenting of the industrial and medical equipment and machine tools cannot be said as a comparables to the company rendering market support services—  Avaya India Pvt. Ltd. vs. Deputy CIT. [2020] 78 ITR [Trib] 84 (Del)